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					   HOMESTEAD FUNDING CORP. d/b/a FIRST NIAGARA MORTGAGE
     INITIAL NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

                                            WHAT INFORMATION WE COLLECT

       We collect nonpublic personal information about our consumers and customers from the
following sources:

           • Information we receive from you during conversations with our employees, or on
             applications or other documents you send to us or your contact with our web site
           • Information we receive from a consumer reporting agency regarding your credit
           • Information about your transactions with us and third parties
           • Information we receive pursuant to your authorization from your present or former
             employers, banking institutions, mortgage servicers, and investments firms
           • Information we receive from banks with whom we do business as a mortgage broker
           • Information received from public or governmental sources


                                 INFORMATION WE DISCLOSE ABOUT YOU

           We do not share any nonpublic personal information about you with anyone except:

     •     Those third parties who perform marketing services on our behalf, or financial
           institutions with whom we have joint marketing agreements that provide for the
           confidentiality and security of your non public personal information.
     •     As permitted by law.

INFORMATION WE DISCLOSE ABOUT CONSUMERS AND FORMER CUSTOMERS

      We do not share any nonpublic personal information about our consumers and former
customers with anyone except:

     •     Those third parties who perform marketing services on our behalf, or financial
           institutions with whom we have joint marketing agreements that provide for the
           confidentiality and security of your non public personal information.
     •     As permitted by law.

              THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR
                       NONPUBLIC PERSONAL INFORMATION

        We restrict access to nonpublic personal information about you to those employees who
need to know that information to provide products or services to you. We maintain physical,
electronic, and procedural safeguards that comply with federal regulations to guard your
nonpublic personal information.
Initial Privacy Notice-01-14-05 First Niagara
                                                DEFINITIONS

      As used in this Initial Privacy Notice, the following terms are intended to have the
meanings expressed below:

      “We”, “our”, “us” and “Homestead”, as used in this Privacy Notice, are intended to
mean Homestead Funding Corp d/b/a First Niagara Mortgage.

      This is our Initial Privacy Notice for our customers. When we use the words “you”,
“your” and “customers”, we mean the following types of customers:

           All of our customers who have a continuing relationship with us, such as:

•    All of our borrowers, or prospective borrowers, for a mortgage loan obtained through us as a
     mortgage banker; or
•    All of our borrowers and prospective borrowers for a mortgage loan arranged through us with
     a different lender, where we are acting as the mortgage broker; or
•    All of the borrowers of mortgages we own and service or arrange to have sub-serviced in our
     name.

       A consumer, for purposes of this Privacy Notice, is anyone who contacts us seeking a
mortgage loan that provides us with any personal information to obtain a mortgage, even if the
loan application is not ultimately consummated with a mortgage loan transaction.

       Nonpublic personal information means information about you that we collect in
connection with providing a financial product or service to you. Nonpublic personal information
does not include information that is available from public sources, such as telephone directories
or government records.

         An affiliated company is a company we own or control, a company that owns or controls
us, or a company that is owned or controlled by the same company that owns or controls us.
Ownership does not mean complete ownership, but means owning enough to have control. We
are affiliated with First Niagara Bank, for instance.

           A nonaffiliated third party is a company that is not an affiliate of ours.




Initial Privacy Notice-01-14-05 First Niagara

				
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posted:8/11/2009
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